Civil Rights
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Brief in Support of Particular Social Group for Asylum
Brief arguing that certain gang based and domestic sexual violence based claims still qualify as a particular social group membership for purposes of asylum post Matter of A-B-. Also argues that certain conclusions reached in Matter of A-B- are flawed and contradict current caselaw.
Complaint for Injunctive Relief & Damages Discrimination
RETALIATORY DISCHARGE IN VIOLATION OF THE FAMILY AND MEDICAL LEAVE ACT, WRONGFUL TERMINATION BASED ON DISABILITY DISCRIMINATION, FAILURE TO PROVIDE REASONABLE ACCOMMODATION
Complaint for Gender Discrimination
Complaint for Gender Discrimination
Civil Rights Complaint – Sex Discrimination & Retaliation
Complaint for Disability Discrimination, Sex Discrimination, Retaliation
Motion to dismiss for Qualified immunity
Motion to dismiss filed by defendant (officers) based on qualified immunity
Motion to exclude firearms in deposition
Motion to modify scheduling order to exclude individuals from carrying firearms in deposition
Stipulated Motion for Protective Orders
A partial stipulated motion for protective orders in an excessive force case
Motion for leave to file excessive pages
Motion for leave to file excessive pages to a response to a motion to dismiss
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES PURSUANT TO 42 U.S.C. § 1988
PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES PURSUANT TO 42 U.S.C. § 1988
PLAINTIFF’S MOTION TO EXCLUDE EVIDENCE OF ALLEGED CODE VIOLATIONS DISCOVERED AFTER AUGUST 2013
PLAINTIFF’S MOTION TO EXCLUDE EVIDENCE OF ALLEGED CODE VIOLATIONS DISCOVERED AFTER AUGUST 2013
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
UNOPPOSED MOTION FOR LEAVE TO TAKE THE DEPOSITION OF AFTER DISCOVERY CUT-OFF
UNOPPOSED MOTION FOR LEAVE TO TAKE THE DEPOSITION OF AFTER DISCOVERY CUT-OFF
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT AND MOTION TO DISMISS
Plaintiff’s Motion to Introduce Summaries into Evidence at Trial
PLAINTIFF’S MOTION TO INTRODUCE SUMMARIES INTO EVIDENCE AT TRIAL